Transfer of an Inheritance Share: Transfers Between Siblings, Sale to a Third Party and Validity of the Contract

An inheritance share may be transferred after the testator's death to another heir by written contract, and to a person who is not an heir by a contract drawn up before a notary public. However, the third party does not become an heir or the direct owner of any real estate through this contract. The third party acquires a right to demand, at the time of division, the share allocated to the transferring heir. The validity and consequences of the transaction vary according to the status of the parties, the date of the contract and the legal position of the assets. The core provisions are Turkish Civil Code No. 4721 (TMK) Articles 677–678.

Statements such as "I left my right to my brother," "I gave a power of attorney before a notary" or "I bought the inheritance share" do not by themselves explain the outcome of the transaction. First it must be determined which right of which testator is being transferred. Then the requirements of form, payment, representation, debts and litigation should be assessed. This article addresses these distinctions under Turkish law and the practical effect of actual Court of Cassation decisions.

The difference between transferring an inheritance share and selling a real estate share

The scope of an inheritance share under joint ownership

An inheritance opens upon death, and heirs acquire the estate as a whole by operation of law. Where there is more than one heir, a joint estate (miras ortaklığı) exists over the estate until it is divided. The share ratio stated in the certificate of inheritance is not a specific room or an independently saleable land registry share of any real estate. Under joint ownership, the right extends to all of the assets pooled together. Selling the whole of an estate asset and an heir transferring his or her own inheritance share are therefore separate transactions. TMK Articles 575, 599, 640, 701–702.

TMK Article 677 permits the transfer of an inheritance share in the whole or in part of the estate. The contract may cover the entire estate, or it may be limited to the inheritance right over specific real estate. However, an heir cannot transfer a right he or she does not hold. Nor can an heir sell a specific asset in its entirety on his or her own by removing the rights of the other heirs. Where the contract refers to "all rights," a later-discovered bank account, receivable or real estate may give rise to a dispute over whether it falls within the scope.

Which rules apply once the property is held in co-ownership?

Where real estate has been divided, or joint ownership has been converted into co-ownership in shares, the later sale of a specific land registry share is assessed under the formal and registration rules that govern real estate transfers. The fact that the seller and buyer are siblings does not, by itself, make a sale by private written document valid. In co-ownership, a sale to a third party also raises the statutory pre-emption rights (önalım hakkı) of the other co-owners where the conditions are met. The same result cannot automatically be attached to a transfer of an inheritance share made while joint ownership continues. TMK Articles 688, 706, 732–734.

The current land registry extract alone may not be enough for this distinction. The type of ownership on the date the transfer contract was made, earlier transfers, division documents and later registrations should be examined together. Different properties belonging to the same family may have different legal positions.

How is an inheritance share transferred between siblings?

Why it matters that they are heirs of the same testator

For a written form to suffice between siblings, the parties must be heirs of the same estate. Kinship alone is not enough. If the acquirer is an heir of a different testator, that does not prevent treating the acquirer as a third party with respect to the estate in question. Both statutory heirs and appointed heirs are considered. Being a creditor under a will (vasiyet alacaklısı) is not the same as being an heir. TMK Articles 516–517, 598, 677.

For this reason, the certificate of inheritance, death and civil registry records, and any earlier disputes over appointed heirship or over the cancellation of dispositions should be reviewed in advance. As a rule, an heir transferring his or her own share does not require all heirs to be parties to the transfer contract. However, the same ease does not apply where the whole estate is to be divided or where the rights of other heirs are to be transferred.

Missing signatures and oral family agreements

In a transfer between heirs, the written form is a condition of validity. An oral agreement within the family does not replace this requirement. In its decision of April 7, 2025, E. 2024/3626, K. 2025/1765, the 7th Civil Chamber of the Court of Cassation (Yargıtay 7. Hukuk Dairesi) upheld the dismissal of a claim for payment in a dispute where there was no written transfer agreement, apart from mutual general powers of attorney. Granting powers of attorney on the same day was not accepted as a contract proving the transfer of the inheritance share itself.

On the question of a missing signature, the content of the document is decisive. In its decision of January 22, 2026, E. 2025/6169, K. 2026/448, the 7th Civil Chamber quashed a rejection based on the absence of the buyer's signature on a contract between heirs, where the transferor had signed. The Chamber considered the transferor's signature sufficient, provided the other elements were present. This does not mean that every missing document is valid, or that a case is certain to be won. In new contracts, documenting each party's clear intent, obligations and signature reduces disputes.

Sale of an inheritance share to a third party and the notary requirement

A notarized contract is not the same as a certified signature

A contract for the transfer of an inheritance share of an opened estate to a person who is not an heir must be drawn up before a notary public. A certified signature and a contract drawn up by a notary are different transactions. The certification of a signature on a text should not be used on the assumption that it satisfies the drafting requirement of TMK Article 677(2). The whole contract and the type of notarial act must be considered. TMK Article 677(2).

A third party should not treat an acquired inheritance share as if it were the title deed to a specific apartment that can be delivered immediately. Estate debts, the rights of other heirs, the manner of division and the scope of the contract all affect the value finally obtained. Calculating the price solely on the basis of the total value of the real estate may hide the debts and the risk of division.

Can the acquirer take part in the division or use the house?

TMK Article 677(2) does not give a third party a direct right to take part in the division. Relying solely on the transfer contract, this person cannot manage the joint estate, take the key to the house by force or make all tenants pay rent to him or her. Where a separate arrangement for management, use or the assignment of claims exists, its conditions are assessed separately.

However, it cannot be said that the third party is entirely unprotected. TMK Article 648 allows the acquirer of an inheritance share in an opened estate to ask the civil court of peace to appoint a trustee (kayyım) to take part in the division in place of the transferring heir. This special means of protection does not turn the acquirer directly into an heir. The request must set out the contract, the share transferred and the need for division. TMK Articles 648 and 677.

Transfer during the testator's lifetime and waiver of inheritance

Participation or consent in the transfer of an unopened estate

While the testator is alive, no inheritance share has yet been acquired. TMK Article 678 does not recognize contracts with other heirs or with third parties concerning a future inheritance right unless the testator participates in them or consents to them. It permits the recovery of performances already rendered. The fact that a transaction was carried out before a notary does not by itself remedy the lack of participation or consent. TMK Article 678.

This provision does not further specify the form of the contract. The analogous application of the form rules for transfers of an opened inheritance share, and the effect of the testator's participation on the transaction, are discussed in legal scholarship. Akkanat Öztürk, 2024, pp. 989–993 addresses the problems of form and characterization with differing views. In practice, it is important to document clearly which transaction, which share and which parties the consent concerns. Consent should not be read as an unlimited guarantee that the testator will keep a specific asset until death.

Distinguishing a waiver from a division agreement

A waiver of inheritance (mirastan feragat) is a separate transaction between the testator and a prospective heir, and it is subject to the form required for inheritance contracts. A "waiver document" signed by siblings among themselves after the death does not become a waiver under TMK Article 528 merely because of its title. A division agreement regulates the distribution of assets and rights among the heirs. TMK Articles 528, 545, 676.

Correct characterization of the document matters for validity, for heirship status, for debts and for the claim sought. Transferring an inheritance share is not a disclaimer of inheritance. In particular, dealings with the estate during the disclaimer period may cause the loss of the right to disclaim under TMK Article 610. The assumption that a person seeking to avoid debts may first sell the share and then disclaim the inheritance carries serious risk. For the consequences of a disclaimer against creditors, see the article on annulment of a disclaimer of inheritance.

The date and actual content of the contract may change the outcome

Today's notary requirement does not apply directly to old contracts

In its decision of January 22, 2024, E. 2022/5291, K. 2024/376, the 7th Civil Chamber of the Court of Cassation examined contracts dated 1980 and 1984. Although it was established that the transferee was not an heir, the Chamber stated that an assessment had to be made under Article 612 of Law No. 743, which was in force on the date of the transaction. It therefore quashed the invalidity ruling that relied on today's notary requirement.

The decision does not mean that a transfer to a third party by a simple private written contract is now possible. The validity of an old legal transaction and the form of a contract concluded today are different questions. The dates of death, contract, payment and division should each be identified, and the provisions of Law No. 4722 on the Enforcement and Application of the Turkish Civil Code should be observed.

A contract titled "transfer" may be a different legal relationship

In its decision of March 2, 2026, E. 2025/3537, K. 2026/1174, the 7th Civil Chamber examined a contract granting a right to a fixed proportion of assets in return for carrying out estate transactions. The lower courts treated the contract as a transfer of an inheritance share and dismissed the claim for lack of form. The Court of Cassation, however, held that the reported facts should be evaluated within the framework of a mandate agreement (vekâlet sözleşmesi) and quashed the judgment.

The result of this decision is not that every transfer of an inheritance share that does not comply with form is valid. The main lesson is that the obligations undertaken must be examined before the title of the contract. Claims for a receivable, expenses, fees or a share transfer may not rest on the same legal cause. A misclassification may affect jurisdiction, time limits and the form of relief sought. Turkish Code of Obligations No. 6098 (TBK) Articles 19 and 502; Civil Procedure Code No. 6100 (HMK) Article 33.

How should the price, rental income and estate debts be arranged?

Stating payment and scope clearly

The contract should clearly state the price, the payment date, any instalments, the account into which payment is to be made, and the delivery and registration obligations. A document evidencing payment is different from a promise to pay. A statement that "the price has been received in full" may cause a later dispute over proof if no payment was in fact made. It is useful for the bank description to state which contract and which instalment the payment relates to.

Rental receivables arising before the transfer, income already collected, claims against the heir who uses the property, and assets discovered later should be expressly included or excluded. A general release clause is not the same thing as a transfer of a specific inheritance share. Specifying the reserved claims and lawsuits reduces the risk that the same economic value is claimed twice, or that a claim is waived unintentionally. The scope of the contract is interpreted according to the parties' genuine and common intent. TBK Articles 19, 97 and 132.

Debts are not discharged automatically

Heirs are, as a rule, jointly and severally liable for estate debts. An heir who transfers his or her share cannot be treated as freed of liability towards creditors automatically by a clause stating that "the buyer will pay the debts." Assuming a debt in the internal relationship is different from a change of debtor as against the creditor. TMK Articles 641, 681–682 and TBK Articles 195–196 should be considered together.

The five-year period in TMK Article 681 concerns the end of joint liability after division. It does not mean that all debts disappear after five years. The starting point is also different for debts that fall due later. Nor can it be said that a third party personally assumes all estate debts solely because of the share transfer. The contract, and any debt assumption that actually took place, must be examined.

As a hypothetical example, assume that the estate assets are Turkish lira (TL) 6,000,000, the estate debts are TL 2,000,000, and two heirs take equal shares. The net share value calculated from these items alone is TL 2,000,000 per person. This calculation does not include tax, liquidation expenses, disputes, changes in value or the risk that the debt cannot be collected. The contract price and the creditor's position must be assessed separately.

On what grounds can an inheritance share transfer contract be annulled?

Non-payment of the price, fraud and exploitation

Non-payment of the price does not automatically make a valid contract void. First, maturity, performance of the counter-obligation, default and the choice of remedy appropriate to the particular contract are assessed. Specific performance with a claim for the price does not produce the same results as rescission of the contract. If the contract is invalid, the basis of a restitution claim may also change. TBK Articles 97, 117, 123–125 and 77–82.

Where mistake, fraud or duress is alleged, the facts that affected the will, when they were learned, and the role of the other party must be explained. A low price alone does not constitute exploitation (aşırı yararlanma). Clear disproportion must be shown to have been obtained by taking advantage of the injured party's distress, thoughtlessness or inexperience. The circumstances of the parties at the time of the contract matter as much as the valuation of the real estate. TBK Articles 28–39.

Capacity, representation and the subsequent buyer

Where lack of capacity is alleged, the capacity to discern at the time of the transaction is examined. Advanced age alone is not enough. Health records and, where necessary, expert review are important. In a transfer of the share of a person under guardianship, the consent rules of the guardianship authority apply. In representation, the scope of the power of attorney and any conflict of interest are examined separately. Where there is a conflict of interest between a child and the legal representative, a need for a trustee (kayyım) may arise. TMK Articles 13–16, 426, 462(9).

Where the disputed real estate has later been transferred to another person, the existence of the first contract does not by itself cancel the later buyer's registration. Trust in the land registry, good faith, the chain of transactions and the position of the defendant are examined under TMK Articles 1023–1024. If registration is not possible, a damages claim based on a valid contract and a restitution claim based on an invalid contract are subject to different conditions. The basis and calculation of an alternative claim must be clearly set out.

Right of action, competent court, mediation and interim measures

The correct claim and the correct parties

Where performance does not take place despite a valid transfer between heirs, depending on the circumstances a claim for cancellation and registration of title, or a claim for a debt, may arise. The third party's right under TMK Article 677(2) relates to the share allocated on division. The same lawsuit form cannot be used without regard to the acquirer's status and the time of performance. In a title action, the rights holder recorded in the register must be identified. In a contractual debt claim, the debtor and, if death has occurred, the successors must be identified. A claim brought on behalf of the whole estate must be separated from a claim based on the person's own transfer contract.

In claims for cancellation and registration of title, and in ordinary contractual debt disputes, the civil court of first instance is competent unless a special rule of jurisdiction applies. Division and partition of co-ownership fall within the duties of the civil court of peace. In actions concerning the title to real estate, the place where the property is located has exclusive jurisdiction. In division actions and certain inheritance disputes between heirs, HMK Article 11 is relevant. Purely contractual debt claims are assessed separately under the general and contractual jurisdictional rules. HMK Articles 2, 4, 6, 10–12.

For disputes over the division of movable or immovable property and over the partition of co-ownership, mediation is a condition precedent to the action. Not every action based on a contract for the transfer of an inheritance share falls within this requirement merely because it concerns an inheritance. Where the real dispute has a commercial, consumer or other special character, the relevant conditions for bringing the action are assessed separately. Law No. 6325 on Mediation in Civil Disputes, Article 18/B.

Interim protection, costs and enforcement of the decision

Filing an action does not automatically suspend the transfer of the property. Where the conditions of HMK Article 389 et seq. are met, an interim injunction (ihtiyati tedbir) may be requested. The request must relate to the right in dispute and be proportionate, and prima facie evidence should be submitted. It should not be assumed that a prohibition on transferring any real estate of the debtor will be imposed in every case concerning a money claim. A precautionary attachment (ihtiyati haciz) is subject to separate conditions. HMK Articles 389–392; Enforcement and Bankruptcy Law No. 2004 (İİK) Article 257.

For actions for cancellation and registration of title, the amount in dispute on which the fee is based is determined by the share sought and the scope of the claim. In its decision of December 26, 2022, E. 2022/3661, K. 2022/8017, the 7th Civil Chamber held that a judgment rendered before the deficient fee had been completed, and shares to be annulled that were not presented in a form suitable for enforcement, were grounds for quashing. A valid contract does not make an incorrectly framed judgment capable of enforcement.

Notary, land registry, on-site examination, expert, service and power-of-attorney costs are separate items. Whether the transaction is for consideration or gratuitous may change the financial consequences. A single "share transfer fee" cannot be given without examining the concrete transaction. For provisions concerning title to real estate, the requirement of finality applies. For money claims, the enforcement route appropriate to the nature of the decision is taken into account. Under the current procedure, the time limit for an appeal (istinaf) and for an appeal on points of law (temyiz) is, as a rule, two weeks from service. Whether a further appeal is open is checked separately. Explanations of correction procedures in earlier decisions cannot be carried over to every current file. HMK Articles 323, 326, 345, 350, 361, 367 and provisional Article 3.

Limitation periods and preclusive periods in transfers of inheritance shares

It is not correct to state a single period for all actions arising from a transfer of an inheritance share. Registration based on a property right, contractual debt, unjust enrichment and defect of will are examined differently. Maturity is the point at which the right to performance can be demanded. It is not always the same as the date of the contract.

In its decision of June 20, 2014, E. 2013/11880, K. 2014/13059, the 8th Civil Chamber of the Court of Cassation treated a transaction in which all heirs participated as a transfer of an inheritance share. It quashed a rejection based on the ten-year limitation period, on the ground that the transaction included a property right. This result should not be extended to all price and restitution claims.

In its decision of February 22, 2021, E. 2017/2476, K. 2021/1113, the 14th Civil Chamber of the Court of Cassation examined a receivable dispute linked to expropriation payments. Taking into account the possibility of division and performance in the concrete case, the Chamber held that the limitation period had not expired. It found the rejection correct as regards a defendant with no written contract. The facts of that decision prevent generalizations such as "the period always runs from the contract" or "it never runs before division."

The basis for the table is TBK Articles 28, 39, 82, 146 and 149, together with the decisions above. Suspension, interruption, earlier law and transitional provisions are assessed for each file separately. For claims characterized as relating to a mandate, the special period in TBK Article 147(5) may also arise. Sending a formal notice (ihtar) does not in every case interrupt the limitation period.

What documents should be prepared for proof?

A party asserting facts must prove the facts it relies on. The rule on the validity of form must not be confused with the rule on proof. The witness exception for transactions between relatives under HMK Article 203 does not, by itself, remove the requirement of a written form for validity under TMK Article 677. HMK Articles 190, 200–203.

• Certificate of inheritance, death and civil registry records, and the basis of any appointed heirship.
• The original of the transfer contract, its annexes, the type of notarial act, and any earlier agreements.
• Current and historical land registry records, transfer and division documents, and cadastral records.
• Bank receipts, invoices and correspondence concerning the price and performance.
• Powers of attorney, representation and permission decisions; and, where a dispute exists, health records as of the date of the transaction.
• Documents concerning rent, use, estate debts, expropriation or the sale price.
• Formal notices and records of service; evidence showing when deception or duress was learned.

In its decision of December 23, 2024, E. 2024/4657, K. 2024/5894, the 7th Civil Chamber of the Court of Cassation upheld the acceptance of an action for cancellation and registration of title based on a written transfer contract between heirs. In the argument over the use of a copy of the document, the Court found that the copy raised no doubt in the concrete file and that the original had not been expressly requested. This decision does not mean that a photocopy answers every objection. Where a signature or content is denied, an examination under HMK Articles 208–216 may be required, so keeping the original is important.

Control sequence to apply before a contract is signed

First, determine whether the inheritance has been opened and identify the heirs of the same estate. Then clarify the right being transferred, the type of ownership and the scope of the contract. Write the price, debts, earlier income and reserved claims together. Once the appropriate form and representation requirements have been completed, determine the order of payment and of delivery or registration. If a dispute arises at the final stage, check that the claim to be brought and the evidence required are consistent with the contract.

For documents signed abroad, the applicable law, form, representation and conditions of use in Türkiye must be examined separately. An apostille is not an approval that cures a defect in the legal content of a document. For real estate in Türkiye, the requirements of Turkish law and of the registration system must be preserved. Law No. 5718, Articles 7, 9, 20–21. For the use in Türkiye of documents issued abroad, see the article on using a foreign certificate of inheritance in Türkiye.

Where a claim of disguised transaction by the deceased (muris muvazaası), abatement or equalization is raised, the relationship between the earlier transfer in dispute and the new transfer contract must be clearly established. Not every transfer of an inheritance share is automatically "asset concealment." On the other hand, the effect of broad release or settlement provisions on earlier claims must not be overlooked. General information does not replace an examination of the concrete document and the chain of transactions.

Conclusion

In a transfer of an inheritance share, the correct solution depends on first identifying the right transferred, before kinship or the title of the document. A written transfer between heirs of the same estate, a transfer to a third party by a notarized contract, and the sale of a co-owned real estate share each produce different legal consequences. Price, debts, income, representation and performance conditions must be built on this distinction.

Where a dispute has arisen, the original contract, the state of ownership on the date of the transaction and the payment records should be examined together. The party, time limit and means of protection should be chosen to match the claim for registration, debt, restitution or invalidity. Transferring an inheritance share does not mean taking immediate possession of a specific property, nor does it automatically release the transferor from estate debts.

For related aspects, see our article on the sale of a house inherited from abroad. You may also read our article on attachment of an inheritance share.

Frequently Asked Questions

Do my other siblings have to sign to transfer my inheritance share to my sibling?

As a rule, where only your own inheritance share is transferred to another heir of the same estate, the signatures of all heirs are not required. However, a transfer of the whole estate, or a transaction affecting the rights of others, is different. Details: transfer between siblings.

Does granting a power of attorney before a notary count as transferring an inheritance share?

Not by itself. A power of attorney confers authority to represent. Whether a transfer contract was concluded, and its scope, must be assessed separately. In a file limited to general powers of attorney, a dismissal was upheld. Details: signatures and written agreement.

Can an inheritance share be transferred before the land registry transfer (intikal) is made?

The acquisition of the inheritance occurs upon death. The absence of a land registry transfer by itself does not prevent a transfer contract. However, heirship, the type of ownership and later registration transactions must be verified separately. Details: joint ownership.

If a third party buys an inheritance share, can that person live in the house?

A transfer contract alone does not give that right of use. The right to demand the value allocated on division and the right to use the house are different. A request for a trustee (kayyım) under TMK Article 648 may be assessed separately. Details: the acquirer's powers.

If the price is not paid, is the title or the contract automatically cancelled?

No. The payment obligation, default and the appropriate choice of remedy must be examined. If the contract is invalid, restitution may arise. If a valid contract has been breached, performance or other contractual claims may arise. Details: price and grounds for annulment.

Can I be pursued for debts after transferring an inheritance share?

The transfer alone does not end liability towards creditors. The assumption of the debt and the creditor's acceptance are assessed separately. The joint liability rule that applies after division does not mean that all debts are cancelled. Details: debt liability.

If an older contract has no notarization, is it absolutely invalid?

A definitive answer requires examining the law on the date of the transaction. A transfer to a third party under Law No. 743 and a transfer made today may not be subject to the same formal regime. Details: older contracts.

Must an action concerning the transfer of an inheritance share always be brought within ten years?

No. The limitation periods for claims for registration, contractual price, restitution and defect of will differ. The starting point may also be tied to different events, such as the contract, maturity, learning of the facts or division. Details: time limits.

Sources and legal bases

Legislation

• Turkish Civil Code No. 4721 (Türk Medeni Kanunu), in particular Articles 13–16, 426, 462, 516–517, 528, 545, 575, 598–599, 610, 640–641, 648, 676–682, 688, 701–702, 706, 732–734, 1023–1024.
• Law No. 4722 on the Enforcement and Application of the Turkish Civil Code (Türk Medeni Kanununun Yürürlüğü ve Uygulama Şekli Hakkında Kanun), in particular Articles 1 and 17.
• Turkish Code of Obligations No. 6098 (Türk Borçlar Kanunu), in particular Articles 19, 28–39, 77–82, 97, 117, 123–125, 132, 146–149, 154, 195–196, 502.
• Civil Procedure Code No. 6100 (Hukuk Muhakemeleri Kanunu), in particular Articles 2, 4, 6, 10–12, 33, 190, 200–216, 297, 323, 326, 345, 350, 361, 367, 389–392 and provisional Article 3.
• Law No. 6325 on Mediation in Civil Disputes (Hukuk Uyuşmazlıklarında Arabuluculuk Kanunu), Article 18/B.
• Enforcement and Bankruptcy Law No. 2004 (İcra ve İflas Kanunu), Article 257.
• Law No. 5718 on Private International Law and Procedure (Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun), Articles 7, 9, 20–21.

Court of Cassation decisions

• 7th Civil Chamber, January 22, 2026, E. 2025/6169, K. 2026/448: Signature of the transferor and other elements of the contract; quashed.
• 7th Civil Chamber, March 2, 2026, E. 2025/3537, K. 2026/1174: Characterization of the contract as a mandate relationship; quashed.
• 7th Civil Chamber, April 7, 2025, E. 2024/3626, K. 2025/1765: General powers of attorney and absence of a written transfer agreement; dismissal upheld.
• 7th Civil Chamber, December 23, 2024, E. 2024/4657, K. 2024/5894: Written transfer, copy of the document and land registry registration; acceptance upheld.
• 7th Civil Chamber, January 22, 2024, E. 2022/5291, K. 2024/376: Form of transactions under Law No. 743; quashed.
• 7th Civil Chamber, December 26, 2022, E. 2022/3661, K. 2022/8017: Fee, determination of shares and judgments capable of enforcement; quashed.
• 14th Civil Chamber, February 22, 2021, E. 2017/2476, K. 2021/1113: Receivable, division, possibility of performance and limitation period; quashed.
• 8th Civil Chamber, June 20, 2014, E. 2013/11880, K. 2014/13059: Limitation period in a transfer involving a property right; quashed.

Academic source

• Elif Beyza Akkanat Öztürk, “The Problem of Characterizing Transactions Concerning Heirs’ Inheritance Rights in Court of Cassation Decisions” (Yargıtay Kararlarında Mirasçıların Miras Hakkını Konu Ettiği İşlemlerin Nitelendirilmesi Sorunu), Ankara University Faculty of Law Journal (Ankara Üniversitesi Hukuk Fakültesi Dergisi), 73(2), 2024, pp. 979–1017; in particular pp. 980–981, 989–995.